EDGI crafted public comments
In January 2020, the Trump administration proposed dramatic regulatory changes that, if instituted, will undermine one of the nation’s most effective environmental laws, the National Environmental Policy Act (NEPA). The Act, celebrating its 50th anniversary this year, is a cornerstone of the laws and regulations put into place in the 1970s to protect the environment … Read more
Submitted by the Environmental History Action Collaborative (EHAC) and members of the Website Monitoring Team, EDGI’s comments finds that the majority of the proposed rule changes are at cross-purposes with the original intent of NEPA, and urges rejection of proposals that: (a) minimize the substantive elements of NEPA; (b) arbitrarily limit the scope and length of EIS review; (c) reduce public participation in the NEPA process; (d) expand categorical exclusions; (e) limit the consideration of indirect and cumulative effects, and (f) restrict judicial review.
EDGI’s comment supports this Office of Science and Technology Policy (OSTP) effort to make data from federally funded research more available and accessible, with comments that focus on the importance of version-control, data accessibility, and facilitation of data utilization.
EDGI’s comment focuses on removals of and reductions in access to online resources directly relevant to the proposed redefinition of Waters of the U.S. (WOTUS) under the Clean Water Act (CWA) that constrain the public’s ability to effectively participate in this rulemaking process, to understand the impacts of the proposed changes to which aquatic resources would be designated as jurisdictional, and to track CWA implementation.
In this comment, we show that transparency, best available science, and
meaningful public participation are not the goal of this rule. Rather, the goal is to
reduce the range of evidence that is used in regulatory decision-making and to
make it harder to use scientific evidence that shows harm caused by chemical
exposures. This rule will prevent deeper understanding by scientists, regulators,
and the public of the risks of chemical exposures and, ultimately, will delay action
to protect environmental and public health.
EDGI’s comment points to the substantial amount of information relevant to the Clean Power Plan and its proposed repeal that was removed from the EPA website over the course of the previous year. For the public and regulated bodies to understand the feasibility of implementing the CPP, they must have continued access to comprehensive information about the purpose and scope of the Plan, the basis for calculating its costs and benefits, technological considerations, and proposed implementation strategies. March 12, 2020 Comment Title: “Public Comments on the Proposed Changes to the National Environmental Policy Act. ” Submitted by the Environmental History Action Collaborative (EHAC) and members of the Website Monitoring Team, EDGI’s comments finds that the majority of the proposed rule changes are at cross-purposes with the original intent of NEPA, and urges rejection of proposals that: (a) minimize the substantive elements of NEPA; (b) arbitrarily limit the scope and length of EIS review; (c) reduce public participation in the NEPA process; (d) expand categorical exclusions; (e) limit the consideration of indirect and cumulative effects, and (f) restrict judicial review.
EDGI’s comments on this proceeding focus on removals of online Clean Power Plan
(CPP) resources, removals that constrain the public’s ability to effectively participate
in the rulemaking process. Reduced access to related resources, especially the
EPA’s climate change websites, also constrains the ability of stakeholders and
regulated entities to stay abreast of implementation feasibility and responsibilities
under the CPP. Finally, access to these resources should continue to be a priority
for effective public participation in relation to the EPA’s ongoing responsibilities for
regulating greenhouse gases
According to our research, the RMP amendments will improve the safety of chemical
processing, improve information access for first responders, and protect local communities. The
amendments also implement good data governance practices to ensure that Local Emergency
Planning Committees (LEPCs) , emergency response officials, and members of the public can5
better access risk assessments and emergency-response information from facilities. By
improving accident prevention program requirements and enhancing emergency preparedness,
the RMP amendments protect communities and first responders.